There were multiple changes to the hospital nursing chapter of the conditions of participation (CoPs) in 2020 and it is anticipated there will be additional changes in 2021. In late 2020, CMS made changes to the section in response to the COVID-19 pandemic for “hospital at home” facilities. There have been over eighteen CMS survey memos of importance issued relating to nursing in the recent past. The final changes were in the Hospital Improvement Rule. This program will discuss plans of care, staffing, policy changes, when an RN is required in an outpatient department, documentation, supervision, nursing leadership, verbal orders, antibiotic stewardship program requirement, and more.
CMS has issued deficiency reports which include which are the most problematic standards for hospitals. The nursing services have been cited over 6,300 times according to the most recent report. This is a must-attend program for any chief nursing officer, clinical nurse or nurse supervisor, or person interested in ensuring compliance with the CMS hospital conditions of participation in nursing. This must-attend program and will discuss the deficiencies and how hospitals can ensure compliance.
CMS made previous revisions to IV medication administration, blood transfusion, safe injection practices, compounding, beyond-use date (BUD), and implemented safe opioid standards. Hospitals continue to struggle with how to comply with these complicated standards, especially the safe opioid interpretive guidelines.
There are many changes in the past to this section include timing of medications, standing orders, soft wrist restraints, and restraint reporting, plan of care, verbal orders, blood transfusions, IV medication, compounding, BUD, antibiotic stewardship program, safe injection practices, self-administration of medications and drug orders.
CMS also issued the final worksheets on QAPI, discharge planning, and infection control which should be on the radar screen of all department managers especially because there were changes in 2020 in all these sections and with interpretive guidelines and survey procedure still to be decided by CMS. There are also proposed changes to the infection control worksheet which will be discussed. All of these sections, components of patient care are impacted to some degree by nursing. That is why it is so important for you to attend this program.
Every hospital that accepts Medicare and Medicaid reimbursement must follow the CMS (Center for Medicare and Medicaid Services) Conditions of Participation (CoPs) and it must be followed for all patients. This program will cover the nursing services section in the hospital CoP manual. Facilities accredited by the Joint Commission, Health Care Facility Accreditation Program, CIHQ, and DNV GL Healthcare must also follow these regulations.
This program will also reference other important sections that all nurses should be aware of that are found outside the nursing services section such as the revised discharge planning standards, medication standards, revised history and physicals, visitation, restraint and seclusion and grievances, and privacy and confidentiality. CMS issued the privacy and confidentiality memo, safe injection practices memo, humidity memo, and insulin pen memo.
This section contains many problematic standards for hospitals including the nursing care plan standards and that an order is required for all medication especially if standing order or protocol used. Staffing, medications, a three-time frame for administering medications, and educational requirements will be discussed along with changes in standing orders and protocols.
Other important sections nurses should be aware of:
Chief nursing officer, all nurses, nurse managers, nurse supervisors, nurse educators, HIM staff, compliance officer, chief of medical staff, Medical staff coordinator, risk manager, patient safety officer, senior leadership, COO, documentation specialist, hospital legal counsel, QAPI director, Joint Commission coordinator, regulatory officers, legal counsel, chief operating officer, chief medical officer, physicians, education department staff, board members, director of health information management, audit staff, and others responsible for compliance with hospital nursing regulations including documentation compliance.
Please note that CMS has a separate CoP for critical access hospitals (CAHs). However, since the CAH nursing CoPs were rewritten on April 7, 2015, and in 2020, they are for the most part the same or a shortened version. These differences are discussed. Any CAH attending can have access to the CAH nursing CoPs because the tag numbers are different. All of the CAH tag numbers changes in 2020.
(BS, JD, RN, CPHRM)
Laura A. Dixon served as the Director, Facility Patient Safety and Risk Management, and Operations for COPIC from 2014 to 2020. In her role, Ms. Dixon provided patient safety and risk management consulting and training to facilities, practitioners, and staff in multiple states. Such services included the creation of and presentations on risk management topics, assessment of healthcare facilities; and development of programs and compilation of reference materials that complement physician-oriented products. Ms. Dixon has more than twenty years of clinical experience in acute care facilities, including critical care, coronary care, peri-operative services, and pain management. Prior to joining COPIC, she served as the Director, Western Region, Patient Safety and Risk Management for The Doctors Company, Napa, California. In this capacity, she provided patient safety and risk management consultation to the physicians and staff for the western United States. Ms. Dixon’s legal experience includes representation of clients for Social Security Disability Insurance providing legal counsel and representation at disability hearings and appeals, medical malpractice defense, and representation of nurses before the Colorado Board of Nursing. As a registered nurse and attorney, Laura holds a Bachelor of Science degree from Regis University, RECEP of Denver, a Doctor of Jurisprudence degree from Drake University College of Law, Des Moines, Iowa, and a Registered Nurse Diploma from Saint Luke’s School Professional Nursing, Cedar Rapids, Iowa. She is licensed to practice law in Colorado and California.
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